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California PRA Doesn't Require Disclosure of Cops' Personnel Files

Freedom Newspapers (newspaper) sued in state court under the state Public Records Act (PRA), Cal. Gov't Code § 3250 at seq, to compel the San Bernardino County Sheriff (Sheriff) to disclose the personnel files of two deputies who were disciplined for beating a suspect. The trial court ordered disclosure, the appellate court reversed and the newspaper appealed.
On appeal, the Supreme Court of California found that the requested records documented the criminal investigation of both deputies. As such, they were exempt from disclosure under the PRA. On that basis, the appellate court's order for the trial court to vacate its order compelling disclosure was affirmed. See: Williams v. Superior Court, 5 Ca1.4th 337; 852 P.2d 337 (1993).

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Related legal case

Williams v. Superior Court